Another Decade Under the Guest Statute

In the nine years which have passed since the writer ventured to express in these pages his views on the Guest Statute, sixteen cases have been decided which deal either with the statute, with joint adventure, or with both. Some of these cases represent major changes in the field, and while no one would for a moment suggest that they have not been carefully noted by the profession there is nevertheless some hope, based not only on reading the opinions, but in some instances on the briefs which led to them, that it might be useful to revisit the topic and bring it up to date. If nothing significant is suggested as to final solutions or future developments, that may be laid to the fact that the writer is gradually becoming somewhat more cautious, and has been made painfully aware that, given the right combination of circumstances, anything may happen in a lawsuit. The primary problem is perennial: what (or who) is "an invited guest of licensee without payment for such transportation," and it is convenient to consider this problem first, leaving the highly specialized topic of joint adventure for later discussion.